There’s no doubt that as an activist investor, former Securities and Exchange Commission boss Richard Breeden can rattle sabres with the best of them — but whether he makes money from it is another matter.

An analysis of Breeden’s eponymous hedge fund reveals that while he may be capable of high-profile power grabs of entities like tax-preparation company H&R Block and jeweler Zale Corp., he’s losing money in several top positions, including ones he’s spent the most time and money battling.

Zale, for example, is trading at roughly $6 a share these days, versus the $23 a share when Breeden first reported his Zale stake in mid-2007. Breeden joined the Zale board in January.

Meanwhile, H&R Block, Breeden’s biggest investment, is trading around $17 a share, but the former SEC chairman began buying shares in 2006, when the stock was trading closer to $24 a share, according to filings. Breeden has since won several director seats and now serves as chairman.

Breeden’s filings, reported late Friday, show stock investments valued at $739 million as of the end of June, compared with more than $838 million at the end of 2008 and more than $1 billion at the end of June 2008.

Victoria Weld, a spokeswoman for Breeden’s firm, said the filings do not “tell the whole picture of the fund or its performance,” though she declined to elaborate.

She did say that Breeden Capital “significantly outperformed the market” in 2008, a year when stocks fell close to 40 percent. And she added the Breeden funds are “up double digits this year,” and said Breeden has assets under management of more than $1.2 billion following “only one redemption since inception, for a total of $5 million redeemed.”

Breeden, who ran the SEC from 1989 to 1993, opened Breeden Capital Management about three years ago, making a splash with a successful run at restaurant Applebee’s International.